Embargoes , Extradition and Sanctions

 

Embargo

 

Embargoes serve as a powerful tool to impose a comprehensive ban on trade, investment, and economic activities, specifically targeting a particular country or group of countries. These measures are strategically implemented to apply pressure on a nation, compelling it to reconsider its policies, actions, or address potential threats. The scope of an embargo can range from restricting specific goods and services to imposing comprehensive economic barriers affecting multiple sectors.

Example : EU embargo on Russia

In response to the Russian involvement in the conflict in Ukraine that started in early 2014, the EU imposed on 31 July 2014 sanctions against Russia, including an arms embargo, by adopting Council Decision 2014/512/CFSP, and Council Regulation (EU) No 833/2014.

The sanctions prohibited any involvement in the supply of arms and services related to military to Russia or dual use items for military use or military end-users in Russia by nationals of EU states or from the territories of EU states, unless contracts or agreements for such supplies had been concluded before 1 august 2014. The prohibition includes involvement in transport or financing of arms and dual use goods for military use for Russia. The prohibition includes the export of items that are to be subsequently re-exported from Russia to a third country.

On 23 and 25 February 2022, after the Russian invasion of Ukraine, the restrictions were amended by prohibiting the sale, supply, transfer or export, directly or indirectly, of goods and technology which might contribute to Russia’s military and technological enhancement, or the development of the defence and security sector.

In addition the import, purchase or transport of arms from Russia was prohibited, unless contracts or agreements had been concluded before 1 august 2014 and with the exception of items and services necessary for the maintenance of equipment already within the EU. 

The embargo was initially in place until 31 July 2015, but has since been extended regularly. It is currently in place.

Extradition

In an extradition, one jurisdiction delivers a person accused or convicted of committing a crime in another jurisdiction, into the custody of the other's law enforcement.

Extradion - India

The Extradition Act 1962, as amended from time to time provides the legislative basis for extradition of a fugitive criminal (FC) from India. A copy of the Extradition Act, 1962 is available at http://www.mea.gov.in.

Central Authority for Extradition Matters

In the Government of India, the Ministry of External Affairs acts as the Central Authority for extradition matters. Within the Ministry of External Affairs, (Consular, Passport and Visa) CPV Division is the nodal point for dealing with extradition matters.

Who is a Fugitive Criminal

‘Fugitive Criminal’ means a person who is accused or convicted of an extradition offence within the jurisdiction of a foreign State and includes a person who, while in India, conspires, attempts to commit or incites or participates as an accomplice in the commission of an extradition offence in a foreign State. (Section 2(f) of Extradition Act, 1962)

The Fugitive Economic Offenders Act (FEOA) of 2018

The Fugitive Economic Offenders Act (FEOA) of 2018 was created to confiscate the assets of people who flee India to avoid criminal prosecution. The act also aims to preserve the rule of law in India. 

The Fugitive Economic Offenders Act, 2018 empowers any special court to confiscate all properties and assets of economic offenders who are charged in offences measuring over INR 100 crores and are evading prosecution by remaining outside the jurisdiction of Indian courts.

Examples of Extradition 

a). Extradition of the 26/11 Mumbai terror attack accused Tahawwur Rana

A US district court first ordered his extradition toIndia in May 2023. After losing his legal battle in lower courts and several federal courts, including the US Court of Appeals for the Ninth Circuit in San Francisco, Rana filed a petition for a writ of certiorari before the Supreme Court on November 13 2024.


On January 21, 2025 the U.S. Supreme Court rejected 63-year-old Rana’s review petition against his extradition. The Pakistani-origin Canadian businessman is accused of playing a key role in the 2008 Mumbai terror attacks as a close accomplice of David Coleman Headley aka Daood Gilani, a Pakistani-origin U.S. national who had done reconnaissance of the potential targets of Lashkar-e-Taiba (LeT) terrorists.

US President Donald Trump on Thursday (13 Feb2025) announced the extradition of the 26/11 Mumbai terror attack accused Tahawwur Rana to India and said he will face justice. He made the announcement at the joint press conference with Prime Minister Narendra Modi following their bilateral meeting at the White House.

Rana, a former doctor and businessman, is a Canadian citizen of Pakistani origin. He was arrested in 2009 in Chicago for his links to a Pakistan-backed terror network. The FBI charged him with supporting Lashkar-e-Taiba (LeT), the terror group responsible for the Mumbai attacks. Though he was convicted in the US for aiding LeT, he was acquitted of charges directly linked to the Mumbai attacks. However, Indian authorities have long maintained that Rana played a crucial role by allowing David Coleman Headley, one of the key planners, to use his immigration business as a cover to conduct reconnaissance in Mumbai.

Once extradited, Rana is expected to face trialin India for his alleged involvement in the attacks that left  A total of 166 people, including six Americans, were killed in the Mumbai terror attacks in which 10 Pakistani terrorists laid a more than 60-hour siege, attacking and killing people at iconic and vital locations in Mumbai between November 23 and November 29 in 2008.


Indian Authorities Prepare for Rana’s Arrival

A team from India’s National Investigation Agency (NIA) is expected to travel to the US soon to complete the necessary formalities. Reports suggest that senior officers of Inspector General and Deputy Inspector General rank will be part of the delegation. Their mission is to oversee Rana’s transfer and ensure all legal requirements are met.
Indian authorities have been pursuing his extradition for years, determined to hold all those responsible for the attack accountable.

With the legal hurdles now cleared, all that remains is the final execution of the extradition order. As the process moves forward, Indian security agencies are preparing for Rana’s return, marking a significant step towards justice for the victims of the 26/11 Mumbai terror attacks.

b). Extradition of Indians left nation after  crimes in India

 The Hon’ble High Court of Justice, King’s Bench Division, London(UK) has today (09/11/2022) dismissed the appeal of fugitive accused Mr.Nirav Deepak Modi in extradition matter.

            On 25th February, 2021, the District Judge, Westminster Magistrates’ Court had handed down his decision and found that there were no bars on the extradition of Mr. Nirav Modi & the Court had sent the case to Secretary of State, U.K. On 15th April, 2021, the Secretary of State ordered Mr.Nirav Modi’s extradition to India. Mr.Nirav Modi filed application before the Hon’ble High Court of Justice, London (U.K.) seeking permission to appeal on multiple grounds. On 9th August, 2021, the High Court of Justice, London gave Mr. Modi the  permission to appeal on the following two grounds:-

  1. His extradition would be incompatible with his convention rights under Article 3 of European Convention on Human Rights; and
  2. It would be unjust or oppressive within the meaning of Section 91 of UK Extradition Act 2003 to extradite him by virtue of his physical & mental condition.

            All other grounds of appeal were rejected.


A high-level team of the Central Bureau of Investigation (CBI), Enforcement Directorate (ED) and the National Investigation Agency (NIA) visited  the United Kingdom in a bid to expedite the extradition of wanted fugitives Vijay Mallya, Nirav Modi, and Sanjay Bhandari, the Times of India reported on 16 Jan 2024.

According to the report, the team headed by a senior officer from the Ministry of External Affairs, sources said. Some meetings have also been scheduled by the Indian High Commission in London with UK officials to seek pending information on the seized assets of the wanted fugitives under the Mutual Legal Assistance Treaty (MLAT).

Vijay Mallya

Beleaguered businessman Vijay Mallya was declared a fugitive in 2019 under the Fugitive Economic Offenders Act, 2018, about four years after he fled to the UK in March 02,  2016. Mallya is wanted over defaulting 17 Indian banks an estimated Rs 9,000 crore that was loaned to now-defunct Kingfisher Airlines (KFA). He is on strict bail conditions, which include providing a bail bond worth 650,000 pounds, surrender of his passport and a ban on possessing any travel documents.

Nirav Modi

Diamond merchant Nirav Modi, wanted in India on fraud and money laundering charges, is currently lodged in Thameside prison, located in London. He had fled from India on January 1, 2018 and was arrested in March 2019 following an extradition warrant based on CBI and ED’s charges against him.

Mr. Modi is currently languishing in privately run Thameside prison in Greenwich, where he was transferred in September 2024 from the Wandsworth jail. On April 16, 2024 he had moved yet another application before the Westminster Magistrate’s Court citing long incarceration. However, it was dismissed during the hearing on May 7, 2024. 


Sanctions


Sanctions represent a set of punitive measures, often economic in nature, imposed by one or more countries against a targeted country, entity, or individual. The purpose of sanctions is to hinder specific actions or activities, such as trade or financial transactions, in order to enforce international laws, safeguard national security interests, and uphold ethical and human rights standards. Sanctions can be unilateral, imposed by a single country, or multilateral, enacted by a coalition of countries or international organizations.

Embargoes and Sanctions can be from powerful players in international trade when applied to nations. Sanctions can be on individuals, groups, any kind of business organisations and nations applied by single country or international organisations as per global charter agreed upon by member nations such as United Nations. 

To address violations of international law, human rights abuses, other state-sponsored crimes, and threats to international security, governments may impose sanctions against designated targets around the world. 

Embargoes & Sanctions - The UN

The Security Council can take action to maintain or restore international peace and security under Chapter VII of the United Nations Charter. Sanctions measures, under Article 41, encompass a broad range of enforcement options that do not involve the use of armed force. Since 1966, the Security Council has established 31 sanctions regimes, in Southern Rhodesia, South Africa, the Former Yugoslavia (2), Haiti (2), Angola, Liberia (3), Eritrea/Ethiopia, Rwanda, Sierra Leone, Côte d’Ivoire, Iran, Somalia/Eritrea, ISIL (Da’esh) and Al-Qaida, Iraq (2), Democratic Republic of the Congo, Sudan, Lebanon, Democratic People’s Republic of Korea, Libya (2), the Taliban, Guinea-Bissau, Central African Republic, Yemen, South Sudan and Mali.

Security Council sanctions have taken a number of different forms, in pursuit of a variety of goals. The measures have ranged from comprehensive economic and trade sanctions to more targeted measures such as arms embargoes, travel bans, and financial or commodity restrictions. The Security Council has applied sanctions to support peaceful transitions, deter non-constitutional changes, constrain terrorism, protect human rights and promote non-proliferation.

Sanctions do not operate, succeed or fail in a vacuum. The measures are most effective at maintaining or restoring international peace and security when applied as part of a comprehensive strategy encompassing peacekeeping, peacebuilding and peacemaking. Contrary to the assumption that sanctions are punitive, many regimes are designed to support governments and regions working towards peaceful transition. The Libyan and Guinea-Bissau sanctions regimes all exemplify this approach.

Sanctions by Countries


The efficacy of sanctions depends on the ability of the issuing country to enforce them. Regulatory bodies, such as the US Department of the Treasury’s Office of Foreign Assets Control (OFAC), publish sanction lists identifying designated targets. Countries then enforce compliance through regulations and impose criminal penalties for violations.

Since sanctioned individuals or entities often seek to circumvent sanctions and continue conducting financial transactions, sanctions screening is crucial to AML regulatory compliance. Financial institutions (FIs) must, therefore, not only understand their compliance obligations but also stay updated on the latest sanctions and implement effective measures to address them. 


Sanctions by India


The Government of India implements sanctions by way of notifications from time to time. These sanctions may be against specific individuals, organizations, or countries. The sanctions imposed by India can generally be classified into two categories: (i) trade / economic sanctions in respect of exports from and imports into India and (ii) sanctions relating to the security and integrity of India. India has economic sanctions in place targeting Iraq, Iran, Somalia and North Korea. Recently, as a result of the border disputes with China, the Government of India has introduced various economic sanctions against China, including banning the use of certain Chinese technology applications in India.

the Indian Government may implement UN sanctions through the United Nations (Security Council) Act, 1947 (“UNSCA”). Under the UNSCA, the Government of India is authorized to take any measures to give effect to any decision of the UN security council.

The most frequently applied measures in India are: arms embargoes; embargoes on nuclear related and ballistic missile related materials; or embargoes on other UN-specified goods or materials.

While India does not have a consolidated list of sanctions, the Indian sanctions regime targets individuals and entities that have been listed by the UN, namely in the ISIL (Da’esh) & Al-Qaeda Sanctions List and the Taliban Sanctions List.


Further, under the Unlawful Activities Prevention Act, 1967 (“UAPA”) (which grants powers to the specified authorities to prevent, monitor and report suspected and identified unlawful activities), the Ministry of Home Affairs, Government of India, (“MHA”) has issued the Prevention and Suppression of Terrorism (Implementation of Security Council Resolutions) Order, 2009 (“2009 Order”). Pursuant to the 2009 Order, the MHA has notified a list of individuals, groups, and organizations which are suspected of being, or are classified as terrorist organizations (“Sanctioned Persons”). The list of Sanctioned Persons is amended by the MHA and the Ministry of External Affairs, Government of India (“MEA”) from time to time.

 

Chapter 2 of the Foreign Trade Policy (“FTP”) provides a list of economic sanctions imposed against countries and regions. Some of the key sanctions set out in Chapter 2 of the FTP are set out below:

(i) the import/export of Arms and related material from/to Iraq is ‘Prohibited’. However, export of Arms and related material to Government of Iraq is permitted subject to a ‘No Objection Certificate’ from the Department of Defence Production. (ii) Trade with the Islamic State in Iraq and the Levant (ISIL, also known as Daesh), Al Nusrah Front (ANF) and other individuals, groups, undertakings and entities associated with Al Qaida has been prohibited. (iii) Direct or indirect import/export from/to Democratic People’s Republic of Korea, import of charcoal form Somalia is prohibited. (iv) Direct or indirect import to Iran or import of specified items, materials or goods from Iran is restricted.


Where any person attempts, makes or abets the carrying out of any import or export in contravention of the provisions of the Foreign Trade (Development and Regulation) Act, 1992 (the “Act”) and the FTP, that person will be liable to a penalty of not less than INR 10,000 and not more than five times the value of the goods or services or technology in respect of which any contravention is made or attempted to be made, whichever is more. The person may also be liable to a penalty under the Customs Act 1962 which includes imprisonment.

Without prejudice to any other penalty which may be imposed, in the case of a contravention relating to specified goods, services or technologies (as defined in the Act), the penalty will be in accordance with the provisions of the Weapons of Mass Destruction and their Delivery Systems (Prohibition of Unlawful Activities) Act 2005, which includes imprisonment.


Further, the Foreign Exchange Management Act, 1999 which regulates the exchange control regime in India provides that if a person contravenes any provision of FEMA or any rule, regulation, notification, direction or order issued under FEMA, then such person shall, upon adjudication, be liable to a penalty up to thrice the sum involved in such contravention where such amount is quantifiable, or up to two lakh rupees where the amount is not quantifiable, and where such contravention is a continuing one, further penalty which may extend to five thousand rupees for every day after the first day during which the contravention continues.


On 30 October 2024, the U.S. Department of Treasury’s Office of Foreign Asset Control (OFAC) sanctioned 21 Indian entities, including 19 companies and 2 individuals from India. This action has been taken by the U.S. Government pursuant to its Executive Order (EO) 14024, which provides for US sanctions against individuals and entities who/that have directly, indirectly or attempted to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support for or on behalf of, or for the benefit of, directly or indirectly, the Government of the Russian Federation.


Government of India is engaged with the U.S. Government on this matter. It has been conveyed to the U.S. Government that India has a robust legal and regulatory framework governing export of controlled and dual-use goods and technologies that is fully in compliance with its international obligations on non-proliferation. As a responsible member of the international community, India actively participates in key multilateral non-proliferation export control regimes (Wassenaar Arrangement, Australia Group and the Missile Technology Control Regime) and contributes to the development and review of their control lists and guidelines. India also ensures the effective implementation of UN Security Council sanctions and the UN Security Council resolution 1540 on non-proliferation. Government also regularly sensitizes Indian companies on export controls, including through regular outreach events in an effort to ensure that companies are not contravening India laws.


India does not have an autonomous (or unilateral) sanctions program, despite being the world’s second most populous nation, the fifth largest economy and an annual exporter of almost $500B in goods and services. Nearly every other large country has an autonomous sanctions program – including China, which started issuing sanctions in 2019 – and so do all of India's immediate neighbors, including Bangladesh. India’s reluctance toward sanctions as a tool of diplomacy traces to the nation’s history as a target of sanctions. Though New Delhi complies with United Nations (UN) sanctions, it has opposed unilateral sanctions as a form of economic protectionism.




Happy Reading,


Those who read this, also read,


1. Combating Financing Terrorism

2.India's CFT and UNSCRs

3. India's CFT - Programme Implementation

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